Vallbona

Defendants Roy C. Springer et al. appeal a judgment after jury trial favoring plaintiffs Maria Vallbona et al. on their complaint for fraud, negligent misrepresentation, and breach of contract. Defendants attack the propriety and amount of the punitive damages award favoring plaintiffs. Defendants also assert evidentiary and instructional errors. We affirm the judgment.

I

Introduction

Knowing the United States Food and Drug Administration (FDA) had not approved use of a low-level laser procedure to remove cellulite, unwelcome lumpy fat deposits especially in the thigh and buttocks, California-licensed physician Dr. Springer opened the Laser Center clinic in Tijuana, Mexico, to perform such procedure. Dr. Springer solicited persons in San Diego to enroll in his Tijuana clinic for laser removal of cellulite. In soliciting plaintiffs, Dr. Springer made various misrepresentations involving past use of the laser procedure in Europe to remove cellulite and the anticipated FDA approval of such procedure for use in the United States. Relying on Dr. Springer’s representations, plaintiffs underwent the laser procedure at his Tijuana clinic without significant removal of…